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The Proposed Broadwater LNG Import Terminal Update of Synapse Analysis

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The Proposed Broadwater LNG Import Terminal Update of Synapse Analysis United States Nuclear Regulatory Commission Official Hearing Exhibit Entergy Nuclear Operations, Inc. In the Matter of: NYS000090 (Indian Point Nuclear Generating Units 2 and 3) ASLBP #: 07-858-03-LR-BD01 Corrected: August 15, 2012 Docket #: 05000247 | 05000286 NYS000090-00-BD01 10/15/2012 ----NYS000045 Exhibit #: Identified: Admitted: 10/15/2012 Withdrawn: Submitted: December 14, 2011 Rejected: Stricken: Other: EXCERPT • The Proposed Broadwater LNG Import Terminal Update of Synapse Analysis January 19,2007 OAGI0000225_ 1 Background In March, 2006, Synapse Energy Economics ("Synapse") released a report entitled "The Proposed Broadwater LNG Import Terminal: An Analysis and Assessment of Alternatives"! ("Synapse Report"). The purpose of the Synapse Report, prepared at the request of Save the Sound,2 was to identify and evaluate potential alternatives to the proposed Broadwater Liquefied Natural Gas (LNG) import terminal in Long Island Sound to meet the long-term energy needs of the New York and Connecticut markets. In brief, the Synapse Report concluded that: • There is no evidence that the regional market requires a base load gas supply facility capable of providing an additional one billion cubic feet per day (bcf/d) of natural gas to meet its immediate or long-term needs. More pressing may be an infrastructure or other investment to address potential supply deficiencies during peak winter heating periods. However, the studies prepared by Broadwater Energy do not substantiate even this requirement for the region; • Other, environmentally preferable approaches to resolving any anticipated peak load supply shortfall would provide economically and socially preferable alternatives to any perceived supply deficiency. Such approaches include increased development and use oflocal storage facilities; investments in natural gas and electric energy efficiency and renewable energy resources; expanded use of combined heat and power technology; and repowering of existing gas-fired power plants to increase fuel efficiency. The report quantified the substantial potential of these resources, and found them to be far more than sufficient to offset projected growth in natural gas demand. The increase in renewable energy assumed in our analysis is consistent with state mandates (called Renewable Portfolio Standards or RPS) in New York and Connecticut; • Even if additional base load sources of natural gas are ultimately required to balance regional demand, Broadwater is not the most promising source of supply. The Bear Head and Canaport LNG import terminals in eastern Canada, for example, are expected to begin receiving deliveries and transporting gas to the northeast United States through the upgraded Maritimes and Northeast pipeline as soon as 2008. The total incremental volume of gas that could be delivered through these new and upgraded facilities will be l.5 bcf per day, and these supplies will be available at least two years earlier than Broadwater could begin operations. These facilities, which are already under construction, are among a number of supply and demand alternatives which do not threaten the integrity of a national 1 http://www.synapse-energy.comlDownloads/SynapseReport.2006-03.Save-the-Sound.Altematives-to­ Broadwater-LNG-Terminal.05-033.pdf 2 Save the Sound (http://www.savethesound.org)isaprogram of the Connecticut Fund for the Enviromuent (CFE; http://www.cfenv.org) dedicated to the restoration, protection, and appreciation of Long Island Sound and its watershed through advocacy, education and research. OAGI0000225_2 environmental treasure3 They have not been given sufficient attention in the discussions over Broadwater. • The proposition that LNG will represent an abundant and inexpensive source of natural gas is not supported by the existing and projected dynamics of the global LNG market. Since the release of this report, a number of events have occurred which make it appropriate to review our analysis and conclusions. These events include: • The delay of the proposed Bear Head LNG terminal in Eastern Canada for lack of reliable source of supply; • The release of updated gas demand forecasts from the U.S. Energy Information Administration (US EIA);4 • The approval of two additional LNG import terminals, located in Massachusetts, to serve the northeast market; 5 • The release of the Broadwater Draft Environmental Impact Statement (DEIS) in November 2006, which addresses some of the issues raised in our report; 6 • The filing of a notice with FERC from the Repsol Energy North America Corporation, developer of the Canaport LNG facility in Saint John, New Brunswick, clarifying that they intend and expect to deliver 0.73 bcf of gas into the northeastern United States; 7 • Certain public claims by Broadwater Energy regarding the economic benefits of the project, specifically their claim that it will save households in the region an average (median) of $300 per year in energy costs from 2011 through 2025;8 • Legislation enacted in 2005 (Public Act OS-I) in Connecticut created a new requirement for electricity suppliers and distribution companies to acquire I % of their supply from combined heat and power, or from commercial or industrial energy efficiency measures to be in place by January 2007. The requirement increases to 4% by January 1,2010; 3 Long Island Sound was designated an "Estuary of National Significance" under §320 of the Clean Water Act in 1988. 4 http://www.eia.doe.govioiaflforecasting.html j http://www.boston.cominewsilocaliarticlesi20061l2i20igovemor approves 2 lng portsi 6 http://www .ferc .gov Iindustriesilngi enviroi eislll-l 7 -06-eis. asp 7 http://elibrary.FERCgovlidmwsifile list.asp?accession num~20070lll-0066 8 http://www.broadwaterenergy.com/index.php?page=econornic benefits OAGI0000225_3 • The Southwest Connecticut region now has around 250 MW of demand-response measures that are used to alleviate generation and transmission congestion in the region. Review of basic conclusions None of these recent events has altered our basic conclusion, that the Broadwater terminal is not required to meet the future energy needs of New York and Connecticut. To the contrary, both of our most basic conclusions have been strengthened. The newer forecasts for gas demand over the next two decades have been revised significantly downward relative to previously available forecasts, largely due to the disappearance of additional gas-fired electricity generation from utility resource plans. This change in projected gas demand for electricity generation is shown in the figure below. Projected U.S. Gas Demand for Electricity Generation 10 ...- /" // J.:./ I ~AEO 05 (Used in DEIS) r I ..... AEO 06 o 2000 2005 2010 2015 2020 2025 2030 Further, Public Act 05-1 in Connecticut, along with the expanded use of demand management in the southwest region of the state, demonstrate that the Synapse report may have been particularly conservative in estimating the future role of these resources in meeting the region's energy needs. Thus we conclude that it is still a preferable and feasible alternative for New York and Connecticut to meet their future energy needs with less costly, lower impact resources such as demand management, development of renewable resources, increased use of combined heat and power, repowering of existing inefficient plants, and increased use of seasonal storage. In addition, the recent events make it even clearer that the region will be experiencing increased diversity and security of gas supply in the future, even without Broadwater. The LNG terminals in Canada and Massachusetts, all much further along than the Broadwater terminal, all add to the available gas supplies for New York and Connecticut. They can do this either directly, by transporting gas to the region through the interstate pipeline system, or indirectly, by releasing pipeline capacity that would otherwise be reserved for moving supplies through the region and northward. OAGI0000225_4 Response to Draft EIS The DEIS contains a discussion of the need for the project which would seem to contradict our conclusions, in addition to some specific discussion of the issues raised in our report. Unfortunately, the DEIS used data which is significantly out of date, particularly with respect to future growth in gas demand and gas-fired electricity generation. Many of the sources used in the DEIS were prepared as long ago as 2002 or 2003. As noted above, the gas demand outlook has changed significantly injust the past year. Further, the DEIS evaluates alternatives such as energy conservation and renewable energy using extremely pessimistic assumptions. For example, the DEIS considers only renewable energy resources that are already planned or proposed, even though the Broadwater facility would be on line no sooner than 20 II, and the relevant period for comparison is the decades thereafter. Quite frankly, we have more confidence in the people and the leadership of Connecticut and New York. Our assessment is that, given the increasing public awareness of the costs in dollars, national security, and damage to the climate that are associated with dependence on fossil fuels, the projections for energy efficiency and demand reduction in the Synapse Report were conservative. As evidence, we note that total natural gas consumption in New York decreased over the past decade, from 1.30 trillion cubic feet in 1997 to 1.16 trillion cubic feet in 2005, according to the US EIA. In responding to the Synapse Report, the DEIS mischaracterizes our assessment as requiring
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